Scope of judicial review in disciplinary matters is confined to decision-making process, excluding reappreciation of evidence.

The petitioner, a Peon in the Department of Revenue posted at Tehsil Chachoda, was suspended on 16.02.2016

Following a departmental enquiry regarding alleged misconduct, the disciplinary authority (Collector, Guna) issued a show-cause notice on 30.03.2017

Despite the petitioner’s reply, the disciplinary authority imposed a major punishment of stoppage of two annual increments with cumulative effect on 05.05.2017

The petitioner’s appeal to the Commissioner, Gwalior Division, was rejected on 05.09.2017

The petitioner challenged these orders via a Writ of Certiorari, alleging a lack of opportunity for cross-examination and that the authorities passed non-speaking, mechanical orders without applying their minds

1. Whether the High Court, in the exercise of its writ jurisdiction under Article 226, can act as an appellate authority to reappreciate evidence in a departmental enquiry.

2. Whether the disciplinary proceedings violated the principles of natural justice and if the punishment was disproportionate.

The court primarily applied the principles of judicial review governing departmental enquiries as established by the Supreme Court in State of Karnataka v. N. Gangraj (2020), which limits the court's power to the decision-making process rather than the decision itself

It further relied on B.C. Chaturvedi v. Union of India (1995) and Union of India v. P. Gunasekaran (2015), which established that High Courts cannot reassess evidence, adequacy, or reliability unless the findings are based on "no evidence" or are perverse

The doctrine of "preponderance of probability" was identified as the standard of proof in departmental matters, distinct from the "proof beyond reasonable doubt" required in criminal trials

The Court observed that the enquiry officer conducted proceedings fairly and the petitioner was provided adequate opportunity to present a defense

Regarding the petitioner's claim of denied cross-examination, the Court noted this objection was raised for the first time in the writ petition and was absent from the prior departmental stages

Applying the precedents of N. Gangraj and Ramesh Dinkar Punde, the Court reasoned that its jurisdiction under Article 226/227 is circumscribed to correcting procedural errors or manifest miscarriages of justice

Since the findings were based on legal evidence and the disciplinary authority agreed with the enquiry report after considering the petitioner’s reply, the Court held it could not substitute its own findings for those of the administrative authorities

The Court found no evidence of perversity or violation of statutory rules

The court concluded that the punishment was based on a proper departmental enquiry and maintained the orders passed by the Disciplinary and Appellate Authorities

Consequently, the petition was dismissed, and no relief was granted